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July 20, 2000


Labeling, superfish, Precautionary principle


AgBioView - http://www.agbioworld.org, http://agbioview.listbot.com

Date: Jul 21 2000 07:17:40 EDT
From: "C. S. Prakash"
Subject: GM Labelling: impossible and unnecessary

From: Alan Moran

GM Labelling: impossible and unnecessary
Australian Financial Review, 18 July 2000

There is no health issue with GM foods, insists Alan Moran

Unless we throw a crowbar into its wheels, the technology will reduce
costs to farmers and eventually consumers. The technology allows plant
output to increase while reducing use of herbicide, water and
nutrients. As the technology develops we will see healthier food (and
vitamin A enriched rice is about to become available with immense benefits
in reducing infant blindness) and food with more appealing tastes.

All cultivated plant food we now eat has been created by the application
of breeding techniques. Previous techniques could bring haphazard changes
and unwanted side effects. The new technology ensures this does not
happen by excluding genes that might have such effects. Moreover, unlike
any previous food product, GM foods undergo exhaustive testing prior to
general release.

Contrary to Ms Sylvan's claims, countless scientific studies have
demonstrated there is no health issue with these products. Nor have any
herbicide superweeds been created. The noted US expert Dr C S Prakash,
who visited Australia two weeks ago, has launched a web site which 3,000
scientists have signed saying the "techniques . can contribute
substantially in enhancing quality of life by improving agriculture,
health care, and the environment." And that, "The responsible genetic
modification of plants is neither new nor
dangerous." To put all fears to rest, in the past few days, seven premier
scientific academies, (including the Chinese and Indian science
academies,the British Royal Society and the US National Academy of
Sciences) have a issued a joint report promoting the benefits of the
technology and their need to feed a growing world population with
increasing aspirations for food quality.

What then of the labelling issue? The technology's most fanatical
opponents are engaged in crop burning to prevent the products being proved
effective. Others are seeking to use red tape to hamper the technology's

Some are opposed to things that are "unnatural", "not necessary", "may
create unforeseen consequences". These terms sound familiar to food
historians because they were used by those opposing pasteurisation of
milk. Proven effective in 1908, it was not until after 1945 that the
objections of the faddists and knee-jerk
opponents could be overcome to allow widespread use of pasteurisation, a
technology that has saved countless lives. Those opposed to GM
technology, like those who sought to prevent pasteurisation and other
earlier advances in food quality, are seeking to demonise it.

Requiring labelling so that consumers can make their own choices sounds
innocuous enough. But a moments thought unveils the difficulties this
entails. First, a great deal of food comprises fresh food which carries
no label. Much is consumed in restaurants and fast food outlets where
labelling is also impracticable.

Other difficulties of labelling occur because almost all the GM foods
presently available are identical to the foods they replace. The
characteristics of the GM plant which produces the food are not found in
or difficult to detect in the food itself. This is because the technology
improves the insect repelling qualities of the plant or allows it to grow
on a shorter stem. To make a clear statement that a product does not
contain any GM material (and processed foods contain hundreds of
ingredients) would entail a vast cost. We would, in fact, be introducing
a GST on food but collecting no revenue and bringing no benefit in terms
of health.

If some consumers want to avoid GM foods, sufficient demand for the
absence of these ingredients will cause suppliers to make the products
available. This already happens with "organic" foods. But
organic food producers could not agree to a standard that guaranteed their
produce to be 100% organic, since it is impossible to be certain of an
absence of an admixture of modern technology.

Hence, the best solution is to leave niche suppliers to market non-GM
products to the customer (if they can do so truthfully). The rest of us
can also buy the products we want without having a needless tax imposed.

These issues are of immense importance to Australia with our considerable
highly competitive agricultural industries. Some claim that "GM free"
might prove a winner in markets overseas. While there may be niche
markets, as there are for "organically " grown foods, they can never be
sufficient to offset a loss of farm productivity. Already, GM technology
brings cost savings to the farmer of about 6 per cent. These savings will
be doubled as the technology becomes more sophisticated, a saving that few
Australian farmers could afford to reject.

Alan Moran is the Director, Deregulation Unit, at the Institute of Public

Date: Jul 21 2000 09:54:36 EDT
From: Greg Conko
Subject: Superfish are no superfix; Question

Jean-Michel Cousteau Watch: Superfish are no superfix for hunger -
7/20/2000 - Features - Environmental News Network - Your leading news
on the environmentFrom the Environmental News Network

Highlights from ENN article (full text below):
"William Muir and Richard Howard of Purdue University discovered that more
than 30 percent of Japanese medaka born with the hGH gene did not live to
sexual maturity. ... [I]n nature, surviving to sexual maturity is
everything. The superfish may dominate the mating game, but if they are
least likely to produce viable offspring, the population will eventually
decline. ... Purdue scientists calculated that if 60 transgenics were
released into a population of 60,000 wild fish, it would only take 40
generations for the species to become extinct."

Has anyone read this paper? If the "superfish" are least likely to produce
viable offspring, as the article suggests, would that not be its own
selection pressure to slowly reduce the occurrance of the gene, or reduce
expression of the phenotype, in wild populations? The superfish would be
more likely to mate than non-transgenic fish, reducing total populations
in the short term, but would this effect really last 40 generations?

-Greg Conko

Date: Jul 21 2000 10:21:46 EDT
From: Greg Conko
Subject: Saunders, Apel, and Precaution

>-----Original Message-----
>From: Andrew Apel [mailto:agbionews@earthlink.net]
>Sent: Monday, July 17, 2000 9:17 PM
>To: AgBioView
>Subject: Math and Precaution
>With Vandana Shiva, we all had to wonder what a physicist
>might know about biotechnology. Now we have to wonder, with
>Dr. Saunders' alleged opinion, what a mathematician can
>offer on the topic.

I think Andrew Apel is being a little too harsh on statistical analysis
and mathematicians. I believe that mathematicians have quite a bit to
contribute to this debate -- and I suspect that Andrew realizes this too.
Andrew is on much more solid ground, though, in his criticism of Peter

Saunders writes: "The precautionary principle states that if there are
REASONABLE scientific grounds for believing that a new process or product
may not be safe, it should not be introduced until we have convincing
evidence that the risks are small and are outweighed by the benefits"
(emphasis added).
Importantly, Saunders adds the equivocation, "reasonable." But this is
contextually incorrect.

The precautionary principle, as incorporated in the 1992 Rio Declaration
(Article 15) reads specifically: "Where there are threats of serious or
irreversible damage, lack of full scientific certainty shall not be used
as a reason for postponing COST-EFFECTIVE measures to prevent
environmental degradation" (emphasis added). In this case, the
"cost-effective" equivocation modifies "measures to prevent environmental
degradation," not the "scientific grounds for believing" a product unsafe.

Moreover, the Wingspread Statement on the Precautionary Principle
incorporates no equivocation: "When an activity raises threats of harm to
human health or the environment, precautionary measures SHOULD be taken
even if some cause and effect relationships are not fully established
scientifically" (See, for example, J. Tickner, C. Raffensperger, and N.
Myers, The Precautionary Principle In Action: A Handbook, published by the
Science and Environmental Health Network, 1999; emphasis added). While
the Wingspread Statement is not an operative legal document, it has been
endorsed by most of the organized environmental movement, and therefore
should be considered in this debate.

Furthermore, as Andrew Apel notes, Saunders commits a clever sleight of
hand, asking us to believe that by placing the burden of proof on
innovators rather than regulators, the precautionary principle follows
centuries-old legal customs. Even the European Commission, in its
February 2000 Communication on the Precautionary Principle, admits: "In
this case, the legislator, by way of precaution, has clearly reversed the
burden of proof by requiring that the substances be deemed hazardous until
proven otherwise"
(http://www.europa.eu.int/comm/off/com/health_consumer/pre-caution.htm, p.

The importance of the precautionary principle's exact phraseology and
burden of proof should not be underestimated, as problems appear not
simply from the principle's plain language, but also from its
interpretation and application within political systems. Of course, the
EC's February 2000 Communication on the Precautionary Principle does argue
that the precautionary principle should not be construed as being a
"search for zero risk" (p. 9), but that doesn't seem to matter much to
real world practitioners of precautionary regulation. Consider a recent
example. In February, the German ministers of health, agriculture,
environment, and research specifically cited the precautionary principle
when jointly calling
for a moratorium on the commercial growth of a Bt-maize variety a single
day before the agriculture ministry's Office for Varieties was expected to
announce its approval (Nature, Vol. 403, p. 821). The German Central
Commission for Biological Safety, a scientific group advising the
government on genetic engineering, announced that the government had
ignored the commission's recommendation for approval and stated that the
commission "could perceive no scientific basis for the decision" (Nature
Vol. 18, p. 476).

As a tool of public policy, the precautionary principle's primary
shortcomings are that it does not describe either the obligations of
regulator or the rights of the innovator, and that it incorporates neither
coherent evidentiary standards nor clear stopping points. As a
consequence, the precautionary principle means in practice only what
legally empowered regulators decide it means. In fact, the EC
specifically declined to define the precautionary principle in its
Communication, writing "it would be wrong to conclude that the absence of
a definition has to lead to legal uncertainty" (p. 10). That brings to
mind the famous quotation from a US judge named Potter Stewart, that he
couldn't define pornography, but he knew it when he saw it. Leaving an
innovator's (or anyone else's) legal rights undefined makes us captive of
the wholly subjective judgment of politicians. In effect, regulators are
given carte blanche to decide what is "unsafe" and
what is "safe enough." Contrary to Saunders' claim, practical application
of the precautionary principle does indeed oblige innovators to prove a
technology's safety to the satisfaction of regulators, even if regulators
demand "absolute proof that something new is safe."

Both Peter Saunders' assertion that advocates of agricultural
biotechnology are "pushing forward with untested ... technologies," and
his claim that advocates are mistaking "absence of evidence is the same as
evidence of absence" are also false. It may be Saunders' opinion that
biotechnologies are "inadequately researched." If that is so, then let
him make that argument and suggest areas for further research. However,
it is patently false to claim that these technologies are "untested."
Furthermore, Saunders seems to misunderstand the risk analysis processes
under which new biotech organisms are evaluated. Regulators never deem
products to be without risk. They only decide that the products have been
examined closely
enough to satisfy them (the regulators) that hypothesized risks are either
unlikely to occur, small enough to be effectively managed, or outweighed
by the products' benefits.

Regarding this last point, probably the most important drawback of the
precautionary principle as a tool for society-wide risk management is that
it encourages us to believe that risk lies only in technological progress.
Unfortunately, risk does not lie only in technological progress; risk also
lies in technological stagnation. Among the risks of technological
stagnation are hunger, poverty, and environmental damage. A more
transcendent approach to risk management would acknowledge that fact, and
would more completely recognize that there are risks in forgoing new
technologies just as surely as there are in adopting new technologies.
New products should not be rejected solely because they may pose new risks.
Instead, we should weigh evidence that new products pose new risks equally
against the evidence that they can reduce or eliminate old risks.

-Greg Conko